Cashins & Associates Blog

Health & Safety: Are Your Written Programs In Compliance?

Posted by Eileen Watkins on Thu, Jan, 19, 2017 @ 14:01 PM

H&S.jpgWritten program documents are an important part of any company's health and safety program.  In fact, they should be considered one of the cornerstones of an effective program.  If you're inclined to think otherwise- and not put any effort into your written programs - then now is a good time to remind everyone that OSHA mandates that certain written programs be in place. 

While it's true that some written programs may not apply to your company (laboratory operations or confined spaces, for example), others apply broadly to many different business types (emergency action plan and hazard communication, for example).  In other words, there's an excellent chance that your company is required to have some written programs in place.  

It's important to make sure that your written programs meet the primary objective of demonstrating compliance with the corresponding OSHA Standard.  We've reviewed numerous health and safety programs and have found that many of them are lacking in this regard.  This finding prompted us to share some written program "do's" and "don'ts".  Read on to learn more.

DON'T write programs that you don't need.  Although this seems obvious, we often find that companies have programs that do not apply to them or their operations.  OSHA's Bloodborne Pathogen standard (and the corresponding Exposure Control Plan) and Fire Prevention Plan are cases in point.

DO write programs that are OSHA mandates for your business. You'll be busy enough implementing these programs. 

DON'T write lengthy programs.  They won't impress your readers - rather, they will overwhelm them.  Long, wordy programs also make it hard to find critical, required information.

DO keep your document as concise as possible. You'll be happy because you won't have to write as much, but more importantly, the document will be easier to comprehend. 

DON'T repeat, re-word, or regurgitate the OSHA Standard in your program document.  This is the most common mistake that we see.  Remember, the main purpose of your program document is to proove that you comply with the OSHA standard- not that you know what the standard says.

DO use your written program to describe how you comply with the various elements of the Standard.  For example, where are your company's Safety Data Sheets stored?  Where do employees congregate after they perform an emergency evacuation? Who serves as the Chemical Hygiene Officer? 

DO make a strong connection between your document and the OSHA standard by using the same words, terms, and outline. Make your section titles identical to the paragraph titles in the OSHA standard.  Organize your document so that your sections follow the order of the standard.  

DON'T use your written program document to deliver OSHA-required training to your employees.  While it can be used as a training supplement, this document shouldn't be the primary vehicle that delivers safety and health information to your employees.  There are several pitfalls to this approach (stay tuned).

DO ensure that information about the OSHA Standard - as well as other background or hazard-related information - is included in the training presentation that corresponds to the written program (since every OSHA Standard that requires a written program also has a training requirement).

DO periodically review your programs and update them to incorporate any changes that have occurred.  Know which OSHA standards require reviews - and how often they're required.

Are your health and safety written programs considered best-in-class? Do you have all the programs that OSHA mandates for your company?  Do you want to find out why OSHA's Bloodborne Pathogen most likely does not apply to your company?  Contact Cashins today - we look forward to hearing from you!

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